Attached is the comment of the ICANN Business Constituency (BC) regarding ICANN Org’s Draft Framework for a Possible Unified Access Model for Continued Access to Full WHOIS Data (20-Aug-2018). This comment was drafted by Mason Cole, Tim Chen, and Margie Milam, with edits by Steve DelBianco. It was approved in accord with the BC Charter. Steve DelBianco Vice Chair for Policy Coordination ICANN Business Constituency